Public Assistance Program 1 DECLARED MARCH 26, 2020 Summary - - PowerPoint PPT Presentation

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MISSOU MISSOURI RI

State Emerg State Emergency ency Man Manageme agement nt Agency Agency DR DR - 4490 4490

Public Assistance Program

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DECLARED MARCH 26, 2020

Summary

STATE: Missouri NUMBER: FEMA-4490-DR INCIDENT: COVID-19 INCIDENT PERIOD: January 20, 2020 and continuing DATE REQUESTED BY GOVERNOR: MARCH 23, 2020 INDIVIDUAL ASSISTANCE: UNDER REVIEW PUBLIC ASSISTANCE: Emergency protective measures (Category B) not authorized under other Federal statutes, including direct Federal assistance, under the Public Assistance program at 75 percent Federal funding for all areas in the State of Missouri HAZARD MITIGATION GRANT PROGRAM: UNDER REVIEW OTHER: Additional designations may be made at a later date if warranted and requested by the state.

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TO APPLY:

Download and complete a Request for Public Assistance (RPA) https://sema.dps.mo.gov/programs/state_public_assistance.php AND Submit your completed RPA to SEMA SEMA.PA@sema.dps.mo.gov OR Set up your Grants Portal account and request an RPA digitally https://grantee.fema.gov/ Upon submission of your RPA to SEMA the Primary and Alternate contact that you’ve provided will receive an email with instructions for accessing FEMA’s Grants Portal. Download and review FEMA’s Public Assistance Program and Policy Guide https://www.fema.gov/media-library-data/1525468328389- 4a038bbef9081cd7dfe7538e7751aa9c/PAPPG_3.1_508_FINAL_5-4-2018.pdf

* Track your incurred costs by codes that are exclusive to COVID-19 * Compile a Damage Inventory of costs incurred as related to COVID-19 * Compile your documentation for submission: payroll policy, procurement policy, insurance policy, primary source documentation (invoices, proofs of payment, timesheets/pay logs, equipment use records, materials and contracts, documentation for volunteer work or donated resources, etc.)

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Request for Public Assistance Form

SUBMIT request within days after Declaration.

DR-4490 Declaration date: March 26, 2020

• PNP sub-grantees must submit additional documentation

WITH the RPA.

THE APPLICA THE APPLICATION PR TION PROCESS OCESS

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FEMA Public Assistance Program and Policy Guide

The Public Assistance Program and Policy Guide (PAPPG) combines all Public Assistance (PA) policy into a single volume and provides an overview of the PA Program implementation process with links to other publications and documents that provide additional process details.

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PUBLIC PUBLIC ASSISTANCE ASSISTANCE

Supplemental 75%/25% (federal/non-federal) cost share assistance to state and local governments and certain private non-profit

• rganizations for response and recovery in a

Presidentially declared disaster or emergency.

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Disaster Event

COVID-19 Governor’s Request Declaration Expedited response Grants Portal Submission Of RPA RPA review For eligibility Damages Identified Funding Projects Formulated Project Review/ Approval Grantee Sub-grantee

* No PDA’s, county thresholds or state thresholds are required for the DR-4490 COVID-19 Major Presidential Disaster Declaration.

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FACTORS FACTORS OF ELIGIBILITY OF ELIGIBILITY

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FACT CTORS OF ORS OF ELIGIBILI ELIGIBILITY TY

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ELIGIBLE ELIGIBLE APPLICANTS APPLICANTS

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PRIV PRIVATE NON TE NON-PR PROFIT OFIT ELIGIBI ELIGIBILITY LITY

• A facility that provides a critical service, such

as education, utility, emergency, medical, or custodial care

• A facility that provides a non-critical, but

essential social service and provides those services to the general public, such as child care, rehabilitation, libraries, museums, zoos, and houses of worship

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ELIGI ELIGIBLE BLE PRIV PRIVATE TE NONPR NONPROFITS OFITS

“Critical services” includes power, water (including irrigation to provide drinking water, fire suppression, or electricity generation), sewer, wastewater treatment, communications, and emergency services.

• OR-

The owner or operator of the PNP that provide non-critical, essential social services has applied for an SBA disaster loan; and has been determined to be ineligible for such a loan (after denial, the PNP can apply to FEMA for possible eligible disaster expenses); or has obtained such a loan in the maximum amount for which the Small Business Administration (SBA) determines the facility is eligible, but the loan does not cover all eligible Permanent Work costs.

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PRIVATE PRIVATE NON NON-PROF PROFIT IT ENT ENTITIES ITIES

• Must submit a PNP Facility Questionnaire (FEMA

Form 90-121)

• A current ruling letter from the IRS granting tax

exemption status OR letter from the State substantiating it is a non-revenue producing, nonprofit entity

• Proof of ownership or legal responsibility
• List of services provided in the facility and when

and to whom (calendar of activities)

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PRIVATE PRIVATE NON NON-PROFIT PROFIT ENTITIES ENTITIES

• Must submit proof of the established purpose of

the facility such as a charter or bylaws and amendments.

• Some PNP’s need not be open to the general

public to be eligible for Public Assistance.

• PNP’s with questions should contact SEMA for an

eligibility determination from FEMA.

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FACT CTORS OF ORS OF ELIGIBILITY ELIGIBILITY

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DEFINITION DEFINITION OF A OF A F FACILITY CILITY

“Public Facility” generally indicates facilities owned by a state

• r local government entity and may include:
• Any flood control, navigation, irrigation, reclamation, public power, sewage treatment and collection, water

supply and distribution, watershed development, or airport facility.

• Any non-federal aid street, road, or highway. (Federal aid roads only eligible for emergency protective

measures).

• Any other public building, structure, or system, including those used for educational, recreational, or

cultural purposes.

• Any park.

“Private Nonprofit Facility” generally indicates an incorporation status files as a 501c classification and may include:

An eligible PNP facility is one that provides educational, utility, emergency, medical, or custodial care, including for the aged or disabled, and other essential social-type services to the general public (further described in Tables 1 and 2, PAPPG). See Appendix B: Private Nonprofit Facility Eligibility (PAPPG, page 170) for various examples of PNP facilities and corresponding eligibility determinations.

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FACT CTORS OF ORS OF ELIGIBILITY ELIGIBILITY

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ELIGI ELIGIBLE BLE EMER EMERGENCY W GENCY WORK ORK

• Emergency Protective Measures *(Category B).
• Eliminate immediate threats to lives or public

health or safety.

• Eliminate immediate threats of significant damage

to improved public or private property. *Examples include: COVID-19 response and supplies, temporary staffing, sheltering, security, etc.

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FACT CTORS OF ORS OF ELIGIBILI ELIGIBILITY TY

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Generally, costs that can be directly tied to the performance of eligible work are eligible. Such costs, according to 2 CFR Part 200*, must be:

• Reasonable and necessary to accomplish the

work.

• Compliant with federal, state, and local

requirements for procurement.

• Reduced by all applicable credits, such as

insurance proceeds and salvage values. * http://www.ecfr.gov/cgi-bin/text-

idx?SID=5d58de650b6270a8bce77b94b5dc677c&mc=true &node=pt2.1.200&rgn=div5

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• It is essential that you accurately document the

expenses incurred in disaster response and recovery

• perations. (2 CFR Part 200)
• Accurate documentation will help you to:
• Recover all of your eligible costs;
• Develop your disaster projects;
• Validate the accuracy of your small projects; and
• Prepare for federal/state audits and financial reviews.

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REASON REASONABLE ABLE

• REVIEW INVOICES PRIOR TO PAYMENT.
• Hours worked versus overtime and time and a

half or double time rates.

• Ineligible costs may not be reimbursed.
• COST INCURRED/PAID ≠

REIMBURSEABLE EXPENSE.

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REASON REASONABLE ABLE

• A cost that is both fair and equitable for the type of

work being performed.

• Reasonable costs can be established through:
• The use of historical documentation for similar work;
• Average costs for similar work in the area;
• Published unit costs from national cost estimating

databases; and

• FEMA cost codes.

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NO DUPLICATION OF BENEFITS

• FEMA cannot provide funding that duplicates insurance

proceeds.

• FEMA cannot duplicate funds provided by another Federal

Agency.

• Grants and cash donations from other sources (CDBG, etc.)

may only be used towards the non-Federal cost share or PA ineligible work.

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PR PROCUREMENT OCUREMENT

• In performing work, applicants must adhere to all

federal, state, and local* procurement requirements.

• Normal procedures must NOT be altered because of

the potential for reimbursement from federal funds.

• Local procurement procedures must meet or

exceed state/federal requirements. *Procurement procedures must be in writing, adopted, and implemented. (2 CFR Part 200)

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CONTRA CONTRACTING CTING

• Contracting with small and minority businesses,

women’s business enterprises, and labor surplus area firms:

• Normally, the non-federal entity must take, and document, all necessary affirmative

steps to assure that minority businesses, women’s business enterprises, and labor surplus area firms are used when possible.

• However, FEMA has issued guidance that is specifically applicable to DR-4490 in which

Awarding agencies may waive the procurement requirements contained in 2 CFR§ 200.319(b) regarding geographical preferences and 2 CFR§ 200.321 regarding contracting small and minority businesses, women's business enterprises, and labor surplus area firms. (FEMA, M-20-17)

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PR PROCUREMENT OCUREMENT

• Contracts must be of reasonable cost, must be

competitively bid, and must comply with federal, state, and local procurement standards.

• Copies of contracts, bid tabs, and identification of

selected contractor must be provided to SEMA and FEMA prior to the reimbursement of funds.

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Procurement Under Grants Conducted Under Exigent or Emergency Circumstances

For “non-state entities”, Federal regulations (2 CFR Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards) establish requirements for the exigency or emergency exception that permits the use of noncompetitive procurements, frequently referred to as “sole-source contracting.” In general, this will be fact-specific and entity-specific as to when exigent or emergency circumstances necessitate the use of noncompetitive procurements. It is essential that all non-state entities understand that both FEMA and the U.S. Department of Homeland Security’s Office of Inspector General (OIG) closely review procurement actions and contract selections, with a particular emphasis on noncompetitive procurement actions, to evaluate compliance with Federal requirements. Failure to follow Federal contracting and procurement requirements puts non-state entities at risk of not receiving reimbursement or not being able to use FEMA grant funds for otherwise eligible costs.

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PR PROCUREMENT OCUREMENT

• Sub-grantee must provide SEMA with written justification for

selection of contractor other than lowest bid PRIOR to award

• f contract.
• SEMA will provide a written response regarding the eligibility
• f the selection back to the sub-grantee.
• The below site may be of assistance to the State and Local

communities when determining whether certain contractors are debarred or not:

• Shortcut to Federal website:
• https://www.sam.gov/SAM/
• Shortcut to State website:
• https://ago.mo.gov/app/search

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PROC PROCUREM UREMENT ENT

The Revised Statutes of Missouri (RSMo) Sections 285.525 through 285.555 (Illegal Immigrants) to ensure that “no business entity or employer shall knowingly employ, hire for employment, or continue to employ an unauthorized alien to perform work within the State of Missouri.”

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PR PROCUREMENT OCUREMENT

• FEMA may reimburse costs incurred under a Time

and Materials contract only if all of the following apply:

• No other contract was suitable;
• The contract has a ceiling price that the contractor

exceeds at its own risk; and

• The Sub-Grantee provides a high degree of
• versight to obtain reasonable assurance that the

contractor is using efficient methods and effective cost controls.

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FEMA does not reimburse costs incurred under a cost plus a percentage of cost contract or a contract with a percentage of construction cost method. Contracts contingent on FEMA reimbursement are strongly discouraged and may jeopardize funding.

PR PROCUREMENT OCUREMENT

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LABOR C LABOR COST ELIGIBILI OST ELIGIBILITY TY

• Force account labor is performed by the

applicant’s employees, rather than by a contractor.

• Claimed at an hourly rate, in accordance with

your existing written policy.

• Labor rates include actual wages paid plus

fringe benefits paid or credited to personnel.

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REA REASSIGNED SSIGNED EMPL EMPLOYEES YEES

• Labor cost for employees assigned to perform tasks

that are not part of their normal jobs is eligible as long as the reassigned employees are performing eligible work. For emergency work, only overtime is eligible.

• The pay rate is based on the reassigned employee’s

normal rate of pay.

• The pay rates must be reasonable.

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TEMPOR TEMPORAR ARY EM Y EMPL PLOYEES YEES

• Temporary employees are extra personnel hired as

a direct result of the disaster to perform eligible work.

• For example, additional nursing staff temporarily

hired to respond to COVID-19.

• Reasonable wages paid to temporary or part-time

employees hired in response to COVID-19 who perform eligible emergency work are eligible; including straight time and overtime.

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FOR FORCE A CE ACC CCOUNT OUNT LAB LABOR OR

• Sub-Grantee can demonstrate the employee was

directly involved with a specific project.

• Individual’s time is normally charged to specific

projects regardless of Federal funding.

• Incurs overtime costs for the employee in

accordance with a labor policy does not include a contingency clause that payment is subject to Federal funding and policy is applied uniformly at all times.

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COM COMPENSA PENSATOR ORY Y TIME TIME

• If a sub-grantee has a policy for providing

compensatory time in place of overtime, FEMA reimbursement will be based on that policy.

• Reimbursement at premium rates for overtime

hours is NOT eligible.

• Costs for compensatory time are eligible at

regular rates, but must be part of the official time- keeping system.

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FRINGE FRINGE BENEFITS BENEFITS

• Fringe benefits that are actually paid as part of an

established policy are eligible.

• Because certain items in a benefit package are

not dependent on hours worked, such as health insurance, the fringe benefit rate will be different for regular and overtime hours.

• The overtime fringe benefit rate is usually

significantly lower.

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MA MATERIA TERIAL L COSTS COSTS

• The cost of materials/supplies that were

purchased or taken from an sub-grantee’s stock and used during the performance of eligible work are eligible.

• If available, actual costs for materials should be

taken from invoices.

• If the materials were taken from stock and

invoices are not available, costs may be developed from the sub-grantee’s historical data

• r by contacting area vendors.

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DONA DONATED TED RESOUR RESOURCES CES

FEMA allows Sub-Grantees to use the value of donated resources (non-cash contributions, property, or services related to eligible Emergency Work) to offset the non- Federal cost share of its eligible Emergency Work Project Worksheets (PWs) and Direct Federal Assistance. FEMA applies the offsets regardless of the cost share arrangements between the Grantee and the Sub-

• grantees. In addition to overarching Federal PA

Program requirements as defined in the PAPPG, the following policy language applies.

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DONA DONATED TED RESOUR RESOURCES CES

The Sub-Grantee may apply the offset if all of the following conditions are met:

• The donated resource is from a third-party (a private entity
• r individual that is not a paid employee of the Sub-Grantee
• r Federal, State, Territorial or Tribal government);
• The donated resource is necessary and

reasonable for accomplishment of the project.

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DONA DONATED TED RESOUR RESOURCES CES

• The Sub-Grantee uses the resource in the

performance of eligible work and within the respective project’s period of performance; and

• The Sub-Grantee or Volunteer organization

tracks the resources and work performed, including description, specific locations, and hours.

• Additional rules apply.

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Public Assistan Public Assistance ce Mana Manage gemen ment t Cost Costs Inte Interim P rim Policy

• licy (FP

(FP 10 104-11 11-2 2 effec effective Augu tive August 1, 201 st 1, 2017) 7)

Management Costs under the Interim Policy

• The following procedures apply to all Sub-grantees that

receive management cost contributions under the Interim

• Policy. Sub-grantees may only request the initial Category Z

Project Worksheet (PW) once projects have been obligated.

• The Category Z PW will be based on the Total Award
• Amount. The Total Award Amount is the actual eligible PA

Project cost, including the non-Federal share, after insurance and any other reductions. It does not include Donated Resources or management costs.

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Public Assi Public Assista stanc nce e Mana Manage gemen ment t Costs Costs Inte Interim P rim Policy

• licy (FP

(FP 10 104-11 11-2 2 effec effective Augu tive August 1, 201 st 1, 2017) 7)

• If and when a Sub-grantee requests a Category Z PW, the

PDMG will formulate a Cat Z PW for 5% of the Total Award Amount obligated for a Sub-grantee at the time of its request. FEMA may process amendments up to once a quarter for 5%

• f the Total Award Amount obligated for the Sub-grantee at

the time of its amendment request.

• EXAMPLE: A Sub-grantee has 5 PW’s with a combined Total

Award Amount obligated at $300,000. The Cat Z PW would be

• bligated for a maximum of 5% of $300,000, or $15,000. If

another PW is obligated, 5% of those costs would be added to the Cat Z PW as an amendment request.

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Public Assistan Public Assistance ce Mana Manage gemen ment t Cost Costs Inte Interim P rim Policy

• licy (FP

(FP 10 104-11 11-2 2 effec effective Augu tive August 1, 201 st 1, 2017) 7)

• If all final actual management costs are known at the time the

Sub-grantee requests a Category Z PW, the Sub-grantee should submit its claim for all eligible costs incurred and FEMA will obligate the Category Z PW based on the actual eligible costs up to the 5% maximum. If additional project costs are obligated or de-obligated, FEMA will adjust the 5% maximum and the actual eligible costs as appropriate.

• FEMA will use Cost Code 9905 to track Sub-grantee costs
• bligated under this Interim Policy.

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Public Assistan Public Assistance ce Mana Manage gemen ment t Cost Costs Inte Interim P rim Policy

• licy (FP

(FP 10 104-11 11-2 2 effec effective Augu tive August 1, 201 st 1, 2017) 7)

TRACKING AND DOCUMENTING MANAGEMENT COSTS

• Sub-grantees must provide documentation to

substantiate costs claimed for eligible management

• activities. Additionally, costs claimed must be

reasonable.

• FEMA will publish a reasonable cost policy specific

to management cost.

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Public Assistan Public Assistance ce Mana Manage gemen ment t Cost Costs Inte Interim P rim Policy

• licy (FP

(FP 10 104-11 11-2 2 effec effective Augu tive August 1, 201 st 1, 2017) 7)

Documentation Requirements

• An explanation of work performed with a

representative sample of daily logs/activity reports. The activity must be related to eligible projects. Therefore, management costs associated with an appeal that is ultimately denied are not eligible. If an eligibility determination is appealed and the appeal is ultimately granted, that project is eligible for inclusion in the calculation of the Cat Z PW and management activities associated with the eligible project costs are eligible for reimbursement.

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Public Assistan Public Assistance ce Mana Manage gemen ment t Cost Costs Inte Interim P rim Policy

• licy (FP

(FP 10 104-11 11-2 2 effec effective Augu tive August 1, 201 st 1, 2017) 7)

Documentation Requirements

• Documentation to substantiate the necessity of any

claimed office supplies, equipment, or space.

• For meetings, the activity description needs to

include the number and purpose of the meetings.

• Travel costs need to include the purpose of travel

and a copy of the travel policy.

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Public Assistan Public Assistance ce Mana Manage gemen ment t Cost Costs Inte Interim P rim Policy

• licy (FP

(FP 10 104-11 11-2 2 effec effective Augu tive August 1, 201 st 1, 2017) 7)

Documentation Requirements

• Training needs to include the location, date(s), and

title of the course. The training must be related to PA and occur within the period of performance of the Cat Z PW.

• Sub-grantees need to certify that the management

activities and associated costs claimed are eligible, consistent with the Interim Policy, and not related to ineligible projects.

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Public Assistan Public Assistance ce Mana Manage gemen ment t Cost Costs Inte Interim P rim Policy

• licy (FP

(FP 10 104-11 11-2 2 effec effective Augu tive August 1, 201 st 1, 2017) 7)

Closeout and Final Reconciliation

• All Cat Z PWs will be reconciled and reimbursed based
• n actual costs not to exceed the maximum percentage

allowed (5% for Sub-grantees). This includes Cat Z PWs that are below the large project threshold.

• The period of performance for all Cat Z PWs for

management costs under the Interim Policy is tied to the timelines provided in Sections C.4 and C.5 of the Interim

• Policy. SEMA must submit its certification of the Sub-

grantee’s Cat Z PW with the final payment of claim and supporting documentation to FEMA within 180 days of the end of the period of performance.

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Project Formulation

Due to the rapid development of the COVID-19 pandemic, FEMA PDMG resources will be assigned but may be utilized according to exceptional cost and/or urgency. Sub-grantees should compile incurred costs that have been coded to COVID-19 with descriptions of work that has been complete and work that remains to be

• completed. This information will be submitted into

Grants Portal for review and submission to FEMA’s Consolidated Resource Center (CRC) for project formulation.

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GRANTS PORTAL New PA Delivery Model Customer Relationship Management Tool CRM - Tool

The Firefox or Chrome browser is recommended for this program.

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You’re INVITED

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REQUEST PUBLIC ASSISTANCE

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SUBMIT REQUEST FOR PUBLIC ASSISTANCE REQUEST

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UPLOAD DOCUMENTS

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UPL UPLOAD ADING ING DOC DOCUMENTS UMENTS

• Recommend you collect copies of the following

documents and upload them to the Portal as soon as possible:

• Current Payroll Policies
• Procurement Policy
• Primary source documentation that supports

costs that have been, or will be, incurred as a response to COVID-19

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TYPES TYPES OF GR OF GRANTS ANTS

The DR-4490 declaration includes only Category B, “Emergency Protective Measures”. See FEMA’s Public Assistance Program and Policy Guide, page 57, for more information.

Approved projects will be divided into two groups:

• LARGE Projects.
• Small Projects.

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Ann Annua uall lly y up upda date ted, d, $1 $131 31,100 ,100 is is th the e FY 20 FY 2020 20 th thre resh shold

• ld amo

amoun unt. t.

LAR LARGE GE PR PROJECT OJECT OR OR SMALL SMALL PR PROJECT? OJECT?

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LAR LARGE GE PR PROJECTS OJECTS

• Federal cost share is obligated when the Project

Worksheet is approved by FEMA.

• Individual Projects greater than $131,100 (adjusted

annually).

• Final cost based on actual documented, eligible cost

as applied to the approved scope of work.

• Final payment made following project completion,

site inspection, files review, and project closed by FEMA.

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SMALL SMALL PR PROJECTS OJECTS

• Federal cost share for a small project is paid upon Project

Worksheet approval by SEMA and FEMA and receipt of all required documentation by SEMA.

• Individual projects less than $131,100 (adjusted annually).
• The minimum amount for a small project is $3,300.00.
• Final cost based on the approved estimate (from the

Project Worksheet) of project cost.

• Cost overruns are resolved in the aggregate.

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SCOPE SCOPE OF W OF WORK ORK

• The Scope of Work on the (Project Worksheet) Sub-

award identifies the approved repair/replacement methodology and eligible costs for completing the project work.

• The Sub-grantee is responsible for completing the

Scope of Work as specified.

• The Sub-grantee is responsible for informing SEMA
• f any conditions that create a need to change the

Scope of Work, BEFORE proceeding with the work.

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Time limits for all Projects begin with the date of the disaster declaration.

COVID-19 Emergency Work Category B - 6 months

(The State has the authority to grant limited extensions.)

PR PROJECT OJECT COMPLETION COMPLETION TIME TIME LIMITS LIMITS

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GRANT GRANT MAN MANAGEMENT GEMENT REQUIREMEN REQUIREMENTS TS

• The (subgrantee) sub-grantee must:
• Complete work within established regulatory timeframes

and request time extensions, as appropriate.

• Submit quarterly progress reports to the (Grantee/State)

Grantee for projects were work is not yet completed.

• Not deposit grant funds in an interest bearing account. If

this occurs, the (subgrantee) sub-grantee must remit any interest earned to SEMA.

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AUDITS UDITS AND AND COMPLIAN COMPLIANCE CE

• (Subgrantees) Sub-grantees must maintain records that

identify the source and application of funds for financially assisted activities.

• (Subgrantees) Sub-grantees must establish a project file

(or site file for multiple site projects) containing the approved corresponding (PW) Sub-award and all documentation pertaining to the project (or site).

• (Subgrantees) Sub-grantees must follow the same or

more stringent internal controls when accounting for and expending disaster grant funds as it does for its annual

• perating revenue.

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AUDITS UDITS AND AND COMPLIAN COMPLIANCE CE

• (Subgrantees) Sub-grantees must maintain

documentation by project, reconcile source documentation to invoices, and determine validity of all project invoices before filing claims.

• (Subgrantees) Sub-grantees must follow federal

procurement standards as set forth in Code of Federal Regulations (CFR) 2 Part 200*

• Improperly contracted work may result in the total

ineligibility for that project.

* Please see additional documentation posted at: https://sema.dps.mo.gov/programs/state_public_assistance.php

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AUDITS UDITS AND AND COMPLIAN COMPLIANCE CE

• (Subgrantees) Sub-grantees will be required to sign

the Audit Compliance Requirements Checklist before any funds are disbursed.

• SEMA reserves the right, as (Grantee) Grantee, to

conduct periodic reviews of any (subgrantees) sub- grantees records and to cease payments to any (subgrantee) sub-grantee found to be non-compliant with these requirements.

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AUDITS UDITS AND AND COMPLIAN COMPLIANCE CE

• Approval of your procurement procedures, cost

documentation, source documents, etc. by representatives of the Federal Emergency Management Agency (FEMA) DOES NOT provide any assurance that auditors will not require that you return disaster grant funds should the Office of the Inspector General (OIG) disagree with those procedures.

• This information and procedures are the result of

previous OIG audits within the State of Missouri.

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All projects are subject to final FEMA/SEMA review.

FIN FINAL AL PR PROJECT OJECT REV REVIEW IEW

Accurate records of expenses must be coded for COVID-19 and maintained by sub- grantees.

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A determination related to federal assistance may be appealed.

The time limit for appeal submission is 60 days from receipt of notice of the action which is being appealed. Submit written appeals to SEMA for processing.

APPEA APPEALS LS

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REM REMEMB EMBER.. ER...

These actions will help you obtain and retain eligible funding in the shortest amount of time:

• TIMELY SUBMISSION OF FORMS, DOCUMENTATION,

AND QUARTERLY REPORTS.

• IF THERE IS ANY DOUBT, ASK BEFORE

COMMITTING RESOURCES.

• MAINTAIN COMPLETE and ACCURATE

DOCUMENTATION, BY PROJECT, OF ALL COVID-19 RELATED COSTS.

• COMPLY WITH THE SCOPE OF WORK.

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REC RECURR URRING ING ISSUES ISSUES

• Documentation of eligible costs.
• Use proper contracts and unit costs.
• Follow approved/established procurement processes in accordance with state and federal

guidelines.

• COMPLY WITH THE APPROVED SCOPE OF WORK.
• Identify all damages and incurred costs.
• Oversight of projects and contracts.
• Documentation of donated resources.
• Information flow to the public.
• Information flow between the Sub-grantee, SEMA, and FEMA.
• FOLLOW THE PROVISIONS OF YOUR CONTRACT.

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REC RECURR URRING ING ISSUES ISSUES

SUBMIT TO SEMA:

• WRITTEN Requests for:
• Change to SOW; Time Extensions; Large Project

Interim Payments; Final Payments;

• Forms; Quarterly Reports; Signed P.4’s

(Project Completion and Certification Report);

• Any other documentation that is requested by

SEMA or FEMA that supports your eligible costs.

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This concludes the overview of the Public Assistance Grant Program

Information provided in this presentation is current as of March 30, 2020.

Additional information can be obtained from:

• The Missouri State Emergency Management Agency

http://sema.dps.mo.gov/programs/state_public_assistance.php

• Your SEMA and FEMA representatives
• FEMA’s Web Site:

https://www.fema.gov/public-assistance-local-state-tribal-and-non- profit

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SEMA DISASTER SECTION

CONT CONTACT CT INFORMA INFORMATION TION

Public Assistance Mailing Address: State of Missouri Emergency Management Agency P.O. Box 116 ATTN: PA Jefferson City, Missouri 65102 Public Assistance Fax Number: (573) 526-9272 SEMA.PA@sema.dps.mo.gov To submit a non-digital RPA David.Burgan@sema.dps.mo.gov (573) 526-9378 Diane.Petty@sema.dps.mo.gov (573) 526-9234 Karen.Cassmeyer@sema.dps.mo.gov (573) 526-9108 Matthew.Boley@sema.dps.mo.gov (573) 526-9131 Regina.Dredge@sema.dps.mo.gov (573) 526-9218

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